Transfer pricing requires evidence for AMP transactions, functionally reliable comparables, and appropriate aggregation or Berry Ratio benchmarking me...
Revisionary jurisdiction cannot reopen share capital assessments where adequate inquiry supports a permissible view and no independent error is establ...
Reassessment jurisdiction fails where unverified portal information is aggregated without examining the taxpayer's explanation or relevance of entries...
Statutory sanction for delayed reassessment requires approval from the prescribed authority; approval by an inferior authority invalidates jurisdictio...
Transfer pricing margin adjustments require matching treatment of non-operating income and related costs, with comparability issues reconsidered on ev...
Preliminary-expense amortisation and MAT exempt-income adjustments prevailed, while trademark costs and managerial remuneration require fresh verifica...
Export valuation requires contemporaneous evidence; unrelated invoices cannot prove overvaluation, and dual penalties on firm and partner are impermis...
HC held that petitioner was entitled to refund of IGST and Service Tax paid on ocean freight following Mohit Minerals precedent. While addressing unjust enrichment concerns, court found petitioner's commitment to refund consumers through tariff adjustments satisfactory. Petitioner established plan to maintain refund amount in separate account for consumer benefit under Electricity Act provisions. Court rejected authorities' transfer of Rs. 23 Crores to Consumer Welfare Fund, finding it inappropriate when mechanism exists to return funds to affected consumers. Orders transferring refund to Consumer Welfare Fund quashed. Authorities directed to refund amount to petitioner within two weeks, with understanding funds would benefit consumers through regulated tariff reductions.
HC held that petitioner was entitled to refund of IGST and Service Tax paid on ocean freight following Mohit Minerals precedent. While addressing unjust enrichment concerns, court found petitioner's commitment to refund consumers through tariff adjustments satisfactory. Petitioner established plan to maintain refund amount in separate account for consumer benefit under Electricity Act provisions. Court rejected authorities' transfer of Rs. 23 Crores to Consumer Welfare Fund, finding it inappropriate when mechanism exists to return funds to affected consumers. Orders transferring refund to Consumer Welfare Fund quashed. Authorities directed to refund amount to petitioner within two weeks, with understanding funds would benefit consumers through regulated tariff reductions.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4800
Join Channel
TaxTMI 
